The end of the first annual continuing professional development (CPD) cycle under the new arrangements is imminent, and all CPD requirements must be met by 30 November 2011. There is a complex array of mandatory CPD requirements for maintenance of general registration with the Psychology Board of Australia, membership of the Australian Psychological Society, and Medicare provider status.
Over the last year the APS has provided members with comprehensive information and tools to assist their understanding and monitoring of the particular requirements pertaining to their individual circumstances. There have been some changes to requirements as the Psychology Board of Australia and Medicare Australia have adjusted some arrangements and issued clarifications, and the APS has endeavoured to keep members abreast of these. This article provides a summary of the available information to assist members to be ready for the 30 November 2011 deadline. Should members have any queries they are encouraged to take the following steps.
- Go to the APS online CPD logging system, which has been designed to assist you to understand your individual CPD requirements and help you to monitor when you have met these. The system has been designed to be self-explanatory and detailed information is embedded within the system to assist with understanding of requirements (go to www.psychology.org.au/cpd/ to access online CPD logging system).
- Consult the comprehensive Guidelines on CPD requirements and other CPD resources on the website that the APS has developed for members (go to www.psychology.org.au/cpd/ ).
- Consult information issued by the Psychology Board for registration CPD requirements (www.psychologyboard.gov.au/Standards-and-Guidelines.aspx ) and the Department of Health and Ageing for Medicare FPS CPD requirements (www.health.gov.au/internet/main/publishing.nsf/Content/mental-ba-focus ).
- Phone or email the APS Member Assistance Centre if your queries aren’t answered by following the steps above (phone 8662 3300 from Melbourne or 1800 333 497 from elsewhere, or email [email protected]).
Who has to meet CPD requirements?
- All psychologists holding general registration with the Psychology Board of Australia
- All APS members holding the grade of Associate Member and above, including members who may not be working as registered psychologists
- All psychologists who are Medicare providers
All CPD requirements must be met by the specified dates for the current annual cycles, as set out below. The same requirements apply for subsequent annual cycles.
Requirements for registered psychologists
Commencing from 1 July 2010 and finishing on 30 November 2011, all psychologists with general registration must have:
- Developed a learning plan to identify learning needs and goals
- Completed 30 hours of CPD activities, which includes 10 hours of peer consultation
- Completed the required proportion of these 30 CPD hours through specialist CPD activities corresponding to any area of practice endorsement that is held (16 hours for one endorsement; 15 hours each for two endorsements)
- Kept a log of all completed CPD activities
- Maintained a journal ‘reflecting’ on all completed CPD activities
All of these requirements must be met in order to be deemed fully compliant with the Psychology Board standard for ongoing general registration. The APS online CPD logging system has been designed to assist members to easily document, log and monitor these requirements through one streamlined program.
How the Psychology Board will know if CPD requirements have been met
Psychologists will be required to declare on registration renewal that they have understood and met the CPD requirements.
Random audits of registered psychologists will be conducted by the Psychology Board following the end of the CPD cycle to ensure that requirements have been met.
Submission of the CPD learning plan, activity log and reflective journal is not required unless selected for an audit. APS online CPD logging records will be accepted by the Psychology Board if a psychologist is audited (supporting documentation as proof of participation in CPD activities may also be required). Please note that although the APS has made the online CPD logging system available to members, the APS is not responsible for monitoring compliance with the mandatory CPD requirements stipulated by the Psychology Board, nor will it provide the Psychology Board with access to either grouped or individual CPD records of APS members.
Consequences of non-compliance
The Psychology Board CPD Standard states that the consequences of failure to comply may be one or more of the following:
- Refusal to renew registration or endorsement;
- Imposition of a condition on registration;
- Requirement to undergo a performance assessment; requirement to undergo an examination; and/or
- Instigation of disciplinary proceedings.
Requirements for APS Associate Members, Members, Fellows and Honorary Fellows*
Commencing from 1 July 2010 and finishing on 30 November 2011, all psychologists must have:
- Developed a learning plan to identify learning needs and goals
- Completed 30 hours of CPD activities, which includes 10 hours of peer consultation
- Completed the required proportion of these 30 CPD hours through specialist CPD activities corresponding to any APS College membership that is held (15 hours for each College)
- Kept a log of all completed CPD activities
- Maintained a journal ‘reflecting’ on all completed CPD activities
The APS online CPD logging system has been designed to assist members to easily document, log and monitor these requirements through one streamlined program. All APS members are strongly encouraged to use the online logging system to log their CPD. Any member who is not in a position to log CPD using the online system must contact the CPD Team at the APS National Office ([email protected]) to make a formal alternative arrangement. In the absence of a formal arrangement, any mailed or emailed CPD records will not be accepted by the APS.
How the APS will know if CPD requirements have been met
The APS will monitor members’ compliance with APS CPD requirements through the APS online CPD logging system and may access individual online records if a member is selected for a random audit (supporting documentation as proof of participation in CPD activities will also be required if audited).
Consequences of non-compliance
Members who do not comply with these requirements will receive a warning only for the first annual cycle in acknowledgement of the complexities of transitioning to the new CPD arrangements. The exception to this applies to APS College members, who will be downgraded to Affiliate Member status if the specialist CPD component of requirements is not met, as per the APS Colleges' previous practices.
* For registered psychologists, these requirements will be met by fulfilling the Psychology Board requirements, with only one minor exception for a small number of members who hold three or more APS College memberships
Requirements for Medicare providers
Focused Psychological Strategies (FPS) Providers
Commencing from 1 July 2011 and finishing on 30 June 2012, all FPS providers must have:
- Completed 10 hours of FPS-related CPD activities. These can be counted towards the 30 CPD hours required by the Psychology Board/APS. Activities completed between 1 July 2011 and 30 November 2011 will be counted towards meeting the Medicare requirement for the 2012 cycle but can also be counted towards meeting the 2011 Psychology Board/APS CPD requirements.
How Medicare Australia will know if CPD requirements have been met
Medicare Australia will monitor compliance through an audit process. The Department of Health and Ageing has yet to release information about the CPD audit process but has stated that this will be provided before the audit process commences. APS online CPD logging records can be used to demonstrate compliance if a psychologist is audited. Supporting documentation as proof of participation in CPD activities may also be required.
Consequences of non-compliance
Billing rights to provide Medicare FPS items will be lost if psychologists do not comply with CPD requirements.
Clinical Psychology Providers
Commencing from 1 July 2010 and finishing on 30 November 2011, all clinical psychology providers must have:
- Completed 16 hours of the 30 CPD hours (required by the Psychology Board/APS) in clinical psychology-related learning activities. This is the same requirement to maintain eligibility for membership of the APS College of Clinical Psychologists and Psychology Board endorsement in clinical psychology.
- Logged these with the APS using the APS online CPD logging system (applicable to those psychologists who attained accreditation to provide clinical psychology Medicare items through the APS Medicare Assessment Team)
How Medicare Australia will know if CPD requirements have been met
The APS will monitor compliance through the APS online CPD logging system, as Medicare Australia has delegated this responsibility to the APS for those clinical psychologists who attained their Medicare credentialing through the APS Medicare Assessment Team.
Random audits will also be undertaken by the APS and supporting documentation as proof of participation in CPD activities will be required.
Consequences of non-compliance
Billing rights to provide Medicare clinical psychology items will be lost if psychologists do not comply with CPD requirements.
Exemptions from meeting CPD requirements
Non-Registered APS Members
Individuals in the following circumstances are exempt from meeting APS CPD requirements:
- APS members who have retired from psychological practice or are not working in a role related to psychology. The APS must be aware of this non-practising status in order for the exemption to be granted.
- APS members who have been granted an exemption by the APS from meeting CPD requirements due to special circumstances.
APS Members Who Are Registered Psychologists
Individuals in the following circumstances are exempt from meeting Psychology Board CPD requirements:
- Psychologists with provisional registration for the full CPD cycle, as their ‘in training’ status indicates that they are already undertaking professional development.
- Psychologists with non-practising registration for the full CPD cycle.
- Psychologists who have been granted a partial exemption for a specified period by the Psychology Board due to ill health, maternity/paternity leave or other special circumstances.
Exemptions granted by the Psychology Board under the circumstances above will be recognised by the APS after verification is provided in writing by the member, and the same exemption from meeting the APS requirements will apply.
Pro rata arrangements
Psychologists who are granted an exemption from meeting CPD requirements for a period of time, or who become eligible to meet CPD requirements part-way through a cycle, will have their CPD hours requirement reduced on a pro rata basis. In the case of registered psychologists, this will be arranged on the basis of the exemption granted by the Psychology Board. Registered psychologists who are granted an exemption for special circumstances will have this recognised by the APS as long as the exemption from the Psychology Board is provided to the APS in writing by the individual member.
Pro rata CPD hours are calculated at the rate of 2.5 hours per month for the number of months of the cycle that the person is eligible to meet the CPD requirements, as set out in the Psychology Board CPD Fact Sheet. However, the Psychology Board has recently advised that in the first year of the national scheme the CPD period is 17 months (June 2010–November 2011), thus the pro rata CPD hours are calculated at the rate of 1.8 hours per month. The adjustment of hours is calculated from the beginning of the next month after the person’s status changes.
There is currently some confusion about exemptions and pro rata CPD arrangements. The APS has been made aware of significant inconsistencies in the Psychology Board /AHPRA’s application of CPD exemptions and pro rata calculations for registered psychologists in special circumstances or those who have attained general registration part-way through the year. These matters have been brought to the attention of the Psychology Board, which has advised that it will develop policies on exemptions from CPD requirements that will be applied consistently across all States and Territories.
Members who have received written notification of CPD exemptions and pro rata calculations from the Psychology Board/AHPRA that are not consistent with the calculations published in the Psychology Board’s guidelines should contact the APS as soon as possible. The APS is retaining a record of these cases to advocate for the problem to be rectified, but individual members are also urged to seek further written clarification from the Psychology Board/AHPRA for their particular circumstances. However, until affected members have received a correction in writing from the Psychology Board/AHPRA, they are advised to comply with the original notification of CPD exemption and pro rata arrangements for their particular circumstances.